The Consumer Financial Protection Bureau has issued an advance notice of proposed rulemaking (ANPR) seeking comments on an array of issues related to prepaid cards which could lead to a broad regulatory rewrite of the fast-growing market for general-purpose reloadable cards (GPRs). The ANPR discourages comment on other types of prepaid cards even though these also fall under the CFPB and could be subjected to a regulatory rewrite. Provisions outlined for GPRs remain in general terms in the ANPR, but the stated purpose – bringing them under the Electronic Funds Transfer Act (EFTA) – would surely redefine these cards even as it creates a precedent for broader changes for non-traditional payment instruments, including emerging mobile ones.

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